Commonwealth distributes a variety of financial products and services to you through its network of independent registered representatives, investment adviser representatives, and insurance agents (“Representatives”). We have always valued the trust our customers place in us and are committed to the responsible management, use, and protection of our customers’ personal information (i.e., information that can be used to identify an individual).
This Policy identifies the ways Commonwealth collects, stores, uses, discloses, and protects the personal information you provide to us when you use our website, located at commonwealth.com (the “Website”), our online services, our mobile applications, our social media pages, and any other product or service that links to this Policy (collectively, our “Services”). If you have entered into a separate agreement with us, that separate agreement shall control, and only those terms within this Policy that do not conflict with such separate agreement shall apply. If you are a Commonwealth Representative, your separate agreement with us, not this Policy, shall apply to our relationship (unless you are a California resident; in that case, please refer to our California Consumer Privacy Act Notice). This Policy does not cover information we receive from third parties. Please note that depending on your relationship with us, other privacy policies may apply in addition to this Policy, such as when you apply for or use Commonwealth financial products or services. By accessing the Services, you agree to the practices regarding your personal information outlined in this Policy. Each time you use the Services, the current version of this Policy will apply. Accordingly, when you use the Services, you should check the date that appears at the top of this document and review any changes since you last looked at the Policy.
Please note: This Policy applies to the websites and online services of Commonwealth and not to those of Commonwealth Representatives. For details about their privacy practices, please contact your Representative.
2. Information We Collect About You
Information You Provide to Us
We collect personal information that you voluntarily provide to us when you use our Services; for example, you may provide us with your contact information, such as your first name and last name, email address, phone number, location, information about your current firm, your approximate assets under management, the content of your communication, or other personal information, when you choose to submit such information to us through email, an online form, or other method (e.g., contacting us through our “Let’s Connect” website feature).
We also collect certain personal information from individuals who are exploring a relationship with us or seeking to learn more about Commonwealth. For example, an individual may inquire about becoming an investor, advisor, or agent with Commonwealth. The types of personal information that we collect will depend upon the specific type of relationship you have or seek with us.
If you interact with us on social media, we may collect your social media profile information, your communications with us, and your communications and posts on our social media pages and forums. If you use any of our chat or communication features, we will collect the content of your communications through such features.
Commonwealth Online Services
We collect personal information when you use or enroll in Commonwealth’s online services, including our mobile applications, such as your name, address, email address, phone number, social security number, and Internet Protocol (IP) address and/or domain, as well as other data you may provide us in connection with your use of our online services, such as information related to a financial product or service, including, but not limited to, investment preferences, demographic information, citizenship information, date of birth, and financial information. This may include your financial account information, account summaries and balances, account performance, and account activity, as well as statements, documents, and reports associated with your account. We may also receive your contact information from a third-party website regarding requests about financial products and services on that website. For Commonwealth clients, we will ask you for contact information to provide you with secure online account access. We may collect and maintain information about your account, online account activity, online services, products requested, and usage of our Website and Services. If you use messaging functions through our mobile application, we collect the content of any message that you send through the mobile application. Communications among users that occur outside our mobile application and Services are not governed by this Policy.
Users of Commonwealth’s online services may also provide us information about their professional advisors, such as their accountant, tax advisor, or attorney, and information about family members and other third parties, such as spouses, children, and beneficiaries.
Envestnet | Yodlee Aggregation Services
Please note that Envestnet | Yodlee is an independent third party. Commonwealth has no control over Envestnet | Yodlee’s use of your data. Commonwealth is not responsible for or able to control the security, confidentiality, or privacy of Envestnet | Yodlee. If you do not agree to Envestnet | Yodlee’s use of your data, do not use Envestnet | Yodlee’s services.
Information We Automatically Collect
When you use our Services, we automatically receive and collect information from your device. This information includes the following:
Information about your device, such as the operating system, hardware, system version, IP address, device ID, and device language
The specific actions you take when you use our Services, including, but not limited to, the pages and screens you view or visit, search terms you enter, and how you interact with our Services
The time, frequency, connection type, and duration of your use of our Services
Information regarding your interaction with email messages; for example, whether you opened, clicked, or forwarded the email message
Identifiers associated with cookies or other technologies that may uniquely identify your device or browser (as further described below)
Pages you visited before or after navigating to our Services
If we have collected your personal information through our “Careers” page in response to a job opening, you are giving us permission to use and retain your information for the purpose of evaluating your application for employment for the specific position you applied to, as well as other roles at Commonwealth. This personal information may be processed and stored by a third-party talent tracking solution provider as well as with vendors, consultants, and other service providers who need access to such information to carry out work relating to the recruitment process on our behalf.
Aggregate Information Collected
Aggregate information is information that does not identify you. It may be collected when you use our Services, independent of any information you voluntarily enter. In addition, we may use one or more processes to de-identify information that contains personal information, such that only aggregate information remains. We may collect, use, store, and transfer aggregate information without restriction.
3. Use and Sharing of Your Personal Information
How We Use Your Information
In general, we collect information and personal information from you so we can provide our Services, operate our business, and provide information you request from us. This includes, but is not limited to, the following:
Provide information, products, or services you request
Verify your identity when accessing our Services
Compare information for accuracy and verify our records
Detect and prevent fraud, security or technical issues, or criminal activities
Evaluate you for an employment position with us (if you apply)
Operate, improve, maintain, and protect our Services
Provide technical and other support
Send updates, marketing communications, and other information about Commonwealth, Representatives, and Services
Send you notices and alerts
Facilitate your subscription to our blog
Conduct research and analytics, monitoring and analyzing trends and usage
Contact you and respond to your inquiries
Send you email newsletters
Register you for an account in our online services
Enhance or improve user experience, our business, and our Services, including the safety and security thereof
Personalize our Services to you
As necessary to comply with any applicable law, regulation, subpoena, legal process, or governmental request
Enforce contracts, our Terms of Service, and User Agreement(s), including investigation of potential violations thereof
Protect against harm to the rights, property, or safety of Commonwealth, our users, or the public as required or permitted by law
How We Share Your Information
We do not rent or sell your personal information.
We may share some of your personal information with third parties that perform services for us. We may also transfer your personal information to third parties under the following circumstances:
To comply with a legal requirement, law, subpoena, judicial proceeding, court order, governmental request, or legal process
To investigate a possible crime, such as fraud or identity theft
In connection with the sale, purchase, merger, asset sale, financing, reorganization, liquidation, or dissolution of Commonwealth, including the evaluation thereof
When we believe it is necessary to protect the rights, property, or safety of Commonwealth or other persons
As otherwise required or permitted by law, including any contractual obligations of Commonwealth
Except as provided in this Policy, we share your personal information at your direction or when we have your consent to do so. If, for example, you connect our Services to third-party software or services, such as your accounting or tax software provider, we will share your information with such provider.If you use our online services, your Representative may have access to your online services account information.
4. Storage and Protection of Your Personal Information
To protect the privacy and security of personal information, we use reasonable administrative, technical, physical, and operational safeguards. Given the open nature of the internet, however, your personal information may be transmitted without security measures over networks connecting you to Commonwealth’s systems and may be accessed and used by parties other than those for whom the data is intended. To safeguard against unauthorized access, Commonwealth employs secure network architectures, such as encryption techniques, firewall barriers, authentication protocols, and intrusion detection. Despite these safeguards and our additional efforts to secure your personal information, we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your personal information.
5. Cookies and Analytics
Our website uses certain analytics tools, such as Google Analytics, Pardot, and VWO, to provide insight into our website and to improve the relevance of advertisements you receive. You may be able to opt out of these analytics tools by visiting the applicable website. If you would like to opt out of Google Analytics, for example, please visit tools.google.com/dlpage/gaoptout.
6. Third-Party Websites and Social Media
The Services may contain hyperlinks to websites operated by third parties, which may include social media features, such as Facebook, LinkedIn, YouTube, Instagram, and Twitter buttons or links. We provide such hyperlinks for your reference and convenience only. We do not control such websites and are not responsible for their content or the privacy or other practices of such websites. It is up to you to read and fully understand their privacy policies. Our inclusion of hyperlinks to such websites does not imply any endorsement of the material on such websites or any association with their operators. If you are submitting information to any such third party through our Services, you should review and understand that party’s applicable policies, including their privacy policies, before providing your information to the third party.
7. California Residents
Under the California Consumer Privacy Act (“CCPA”), California residents have certain rights regarding their personal information. Please see our California Consumer Privacy Act Notice for further information.
8. Children’s Privacy
Our Services are not intended for use by children younger than 13, and we do not knowingly collect personal information from children younger than 13.
9. Updating and Correcting Your Personal Information; Opt Out
If your personal information or account information is incomplete, inaccurate, or outdated, please contact your Representative (if applicable) or Commonwealth at 800.251.0080.
If you no longer wish to receive our marketing and promotional communications, you may opt out by following the instructions included in each communication.
10. Questions About Your Privacy
Please email firstname.lastname@example.org if you have questions or concerns regarding our use of your personal information or this Policy.
This Policy is subject to change without notice and should be reviewed each time you use our Services. You should also check the date of this Policy to see whether changes have been made since the previous version. Changes to this Policy take effect when the revised Policy is posted. You accept the revised Policy when you use the Services following any changes.